Short-Form Employee Data Protection Policy Template

This Short-Form Employee Data Protection Policy is designed for use as an internal policy document and has an HR focus, dealing specifically with employees’ personal data.

The provisions of this policy template set out the rights of employee data subjects, as laid out in the GDPR, and their employer’s obligations in its role as a data controller.

This document has been written as a “short-form” alternative to our standard Employee Data Protection Policy. Most of the core provisions are virtually the same; however, some more detailed sections have been removed and replaced with references to separate policies (e.g. our IT Security Policy).

Please note that this document is designed for HR use in business only. The terms used throughout establish and employment focus which makes this template unsuitable for use in other contexts. A general Short-Form Data Protection Policy is also available. Please also note that certain provisions of the GDPR relating to public authorities and other official bodies have not been fully incorporated.

Optional phrases / clauses are enclosed in square brackets. These should be read carefully and selected so as to be compatible with one another. Unused options should be removed from the document.

This Short-Form Employee Data Protection Policy contains the following clauses:

1. Introduction
2. Definitions
3. Data Protection Officer & Scope of Policy
4. The Data Protection Principles
5. The Rights of Data Subjects
6. Lawful, Fair, and Transparent Data Processing
7. Consent
8. Specified, Explicit, and Legitimate Purposes
9. Adequate, Relevant, and Limited Data Processing
10. Accuracy of Data and Keeping Data Up-to-Date
11. Data Retention
12. Secure Processing
13. Accountability and Record-Keeping
14. Data Protection Impact Assessments and Privacy by Design
15. Keeping Data Subjects Informed
16. Data Subject Access
17. Rectification of Personal Data
18. Erasure of Personal Data
19. Restriction of Personal Data Processing
20. [Data Portability]
21. Objections to Personal Data Processing
22. [Automated Processing, Automated Decision-Making, and Profiling]
23. Personal Data
24. Sharing Personal Data
25. Transferring Personal Data to a Country Outside the [UK and] EEA
26. Data Breach Notification
27. Implementation of Policy

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